Surprise medical billing occurs when a patient unexpectedly receives a bill for healthcare services they believed would be covered by their insurance, often due to out-of-network providers being involved in their care without their knowledge.
To address this, the No Surprises Act, which took effect January 1, 2022, continues to protect patients in 2025 from most surprise medical bills for emergency services, non-emergency services from out-of-network providers at in-network facilities, and air ambulance services.
According to the U.S. Department of Health & Human Services (HHS), the Act requires:
In 2025, enforcement of these rules has expanded, with increased penalties for violations and greater scrutiny on compliance processes for healthcare providers.
Even with the No Surprises Act in effect, billing errors and disputes can still occur in 2025. While the law has reduced the frequency of unexpected charges, certain real-world challenges continue to cause issues for patients, healthcare providers, and insurers.
Insurance networks can be highly complex, especially in large metropolitan areas or multi-specialty hospitals. Patients may assume that every provider they see in an in-network facility is also in-network, but this is not always the case. For example, a cardiologist, anesthesiologist, or radiologist involved in a patient’s care may work for a separate group that is out-of-network, triggering higher charges. Without clear and early communication, these situations can lead to unexpected bills and patient frustration.
Accurate insurance verification is one of the most important steps in the billing process, yet it’s also one of the most common points of failure. If a patient’s insurance information is outdated, entered incorrectly, or not fully verified before treatment, the claim may be processed at out-of-network rates or denied entirely. Similarly, delays in updating patient information or submitting claims can result in missed filing deadlines, forcing the patient to be billed directly.
In emergencies, patients rarely have the ability—or the time—to choose their providers. If a patient is rushed to the nearest hospital, they may receive care from on-call specialists, ambulance services, or air ambulance providers who are not in their insurance network. While the No Surprises Act offers protections in many of these cases, complex billing rules and multi-party claims can still cause confusion and disputes between payers and providers.
Billing is a multi-step process involving providers, front-office staff, billing teams, and insurance companies. If there is miscommunication between these parties—such as missing authorizations, incorrect coding, or incomplete documentation—the claim may be delayed, denied, or paid incorrectly. In some cases, insurance companies may receive conflicting information from the provider and the facility, leading to processing errors and disputes that take months to resolve.
Perspectives on the Surprise Billing Issue
The Surprise Medical Billing discussion in 2025 involves multiple stakeholders, each with their own challenges, responsibilities, and expectations under the No Surprises Act. Understanding these perspectives helps healthcare providers navigate compliance, maintain financial health, and ensure patient satisfaction.
Patients are at the heart of the No Surprises Act. They want predictable, transparent costs and protection from unexpected bills—especially when they have no control over which providers are involved in their care.
In 2025, patients are more informed and proactive than ever, thanks to online resources, patient portals, and increased public awareness campaigns. Many know their rights under the law and are quick to challenge bills that appear to violate federal protections.
Patients also expect providers to give good-faith estimates before treatment, explain insurance coverage clearly, and resolve billing disputes quickly. A failure to meet these expectations can not only lead to patient dissatisfaction but also trigger formal complaints or legal action.
Providers, including hospitals, clinics, and independent practitioners, must balance regulatory compliance with operational and financial realities.
The No Surprises Act requires strict adherence to coding accuracy, network verification, and disclosure rules. However, these requirements often increase administrative workload, especially for providers without a dedicated compliance or billing team.
Errors such as incorrect coding, missing authorizations, or poor communication with insurance carriers can lead to denied claims, underpayments, or delays in reimbursement. For smaller practices, repeated denials can cause significant cash flow strain, affecting their ability to invest in staff, equipment, and patient services.
Insurance carriers play a central role in surprise billing disputes. Their primary goal is to control healthcare costs for their members while ensuring they meet the legal obligations of the No Surprises Act.
For insurers, paying out-of-network providers at regulated rates can be challenging—especially in high-cost emergency or specialty care situations. They must maintain accurate provider directories, implement clear claims processing workflows, and participate in the Independent Dispute Resolution (IDR) process when disagreements arise over reimbursement amounts.
From the insurer’s perspective, balancing cost control with compliance requires tight coordination between claims departments, provider relations teams, and legal counsel.
The U.S. Department of Health & Human Services (HHS), along with the Departments of Labor and Treasury, is responsible for enforcing the No Surprises Act and providing ongoing guidance to the industry.
In 2025, regulators are expanding enforcement efforts, increasing penalties for non-compliance, and refining IDR procedures to make them faster and more transparent. They also issue technical updates to clarify gray areas in the law, such as defining emergency service scope, addressing telehealth billing, and improving dispute resolution timelines.
Regulators also face the challenge of balancing patient protection with provider viability, ensuring that compliance requirements do not unintentionally cause service shortages or discourage specialists from participating in certain networks.
How Bridge Billing Services Helps Healthcare Providers Navigate Surprise Billing Challenges
Bridge Billing Services specializes in certified billing solutions that help providers avoid compliance issues and maintain healthy revenue cycles.
Here’s how we support practices in the evolving regulatory landscape:
We confirm patient insurance coverage and network status before services are rendered whenever possible—helping avoid out-of-network surprises.
Our billing specialists ensure every claim reflects correct ICD-10 and CPT coding, along with all required modifiers and documentation for compliance with the No Surprises Act.
We streamline the billing cycle from claim creation to payment posting, reducing administrative errors that lead to disputes.
If a claim is questioned under the No Surprises Act, we handle claim appeals and documentation requests to support your right to fair reimbursement.
We help healthcare providers maximize cash flow while staying compliant—reducing bad debt from uncollected patient balances.
We provide clear, easy-to-understand billing statements to patients, ensuring transparency and reducing the risk of disputes.
The Role of Billing Outsourcing in Preventing Surprise Medical Bills
Billing outsourcing
offers several benefits for providers navigating these regulations:
Preparing for the Future of Surprise Billing Compliance
The regulatory landscape will likely continue to evolve. In 2025 and beyond, providers can expect:
By partnering with a knowledgeable billing team like Bridge Billing Services, healthcare providers can confidently adapt to these changes without sacrificing efficiency or patient trust.
Surprise medical billing remains a critical issue in 2025, even with strong federal protections in place. Providers must stay proactive—verifying insurance, ensuring accurate coding, and maintaining open communication with patients and payers.
Bridge Billing Services offers the billing solutions and expertise needed to keep your practice compliant, your revenue cycle strong, and your patients informed.
📞 Contact us today to learn how we can help you navigate billing compliance and streamline your billing process.
Disclaimer: This article is for informational purposes only and should not be considered legal or medical billing advice. Please consult a qualified professional for your specific situation, like Bridge Billing Services.